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`DR. THOMAS F. LA PORTA
` UNITED STATES PATENT AND TRADEMARK OFFICE
`- - - - -
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - -
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.,
`Petitioners
`v.
`FOCAL IP, LLC,
`Patent Owner
`- - - - -
`Case IPR2016-01259
`Patent Number: 8,155,298
`Case IPR2016-01261
`Patent Number: 8,457,113
`Case IPR2016-01262
`Patent Number: 7,764,777
`Case IPR2016-01263
`Patent Number: 8,155,298
`- - - - -
`VIDEOTAPED DEPOSITION OF DR. THOMAS F. LA PORTA
`VOLUME I
`February 23, 2017
`State College, PA
`Reported by: Michelle L. Hall
`Job No. 119416
`
`TSG Reporting - Worldwide 877-702-9580
`
`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 1
`La Porta Deposition Excerpts
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`DR. THOMAS F. LA PORTA
`VIDEOTAPED DEPOSITION OF DR. THOMAS F. LA PORTA
`a witness herein, called by Patent Owner for
`examination, by and before Michelle L. Hall, a
`Registered Merit Reporter and Notary Public in
`and for the Commonwealth of Pennsylvania, at
`the Ramada State College Hotel & Conference
`Center, 1450 South Atherton Street, State
`College, PA, on Thursday, February 23, 2017, at
`9:45 a.m.
`- - - - -
`
`COUNSEL PRESENT:
`For the Petitioners:
` Christopher Tyson, Esquire
` Patrick McPherson, Esquire
` Duane Morris
` 505 9th Street, N.W.
` Washington, DC 20004
` Sarah Guske, Esquire
` Baker Botts
` 101 California Street
` San Francisco, CA 94111
` Jaspal Hare, Esquire
` Spencer Fane
` 10100 North Central Expressway
` Dallas, TX 75231
` (via teleconference)
`And
` Gardiner Davis, Esquire
` Spencer Fane
` 1000 Walnut Street
` Kansas city, MO 64106
` (via teleconference)
`
`TSG Reporting - Worldwide 877-702-9580
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`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 2
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`DR. THOMAS F. LA PORTA
`COUNSEL PRESENT (CONT.):
`For the Patent Owner:
` John Murphy, Esquire
` Nelson Bumgardner
` 3131 West 7th Street
` Fort Worth, TX 76107
`
` Hanna Madbak, Esquire
` SiberLaw
` 28 W. 44th Street
` New York, NY 10036
`ALSO PRESENT:
`Regis J. (Bud) Bates
`Victoria Ferrandino, Legal Video Specialist
`
`TSG Reporting - Worldwide 877-702-9580
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` DR. THOMAS F. LA PORTA
` I N D E X
` - - - - -
` WITNESS: DR. THOMAS F. LA PORTA
`
`E X A M I N A T I O N: PAGE
`
`BY MR. MURPHY 7
`
`E X H I B I T S (First Referenced):
`
`EXHIBIT 1001 Patent No. US 8,457,113 B2 37
`June 4, 2013
`EXHIBIT 1002 Declaration of Thomas F. 12
`La Porta in Support of Petition for Inter
`Partes Review of U.S. Patent No. 8,457,113
`EXHIBIT 1004 Patent No. 5,958,016 297
`September 28, 1999
`
`EXHIBIT 1006 Patent No. US 7,764,777 37
`July 27, 2010
`EXHIBIT 1007 Patent No. US 8,155,298 B2 37
`April 10, 2012
`
`EXHIBIT 1010 Notice Regarding Change of 211
`Power of Attorney. Date Mailed:
`09/25/2014. Pages 1 through 88 and
`Pages 1567 through 1569
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` DR. THOMAS F. LA PORTA
`E X H I B I T S (Marked):
`
`EXHIBIT 2010 Patent No. US 6,574,328 B1 214
`June 3, 2003
`EXHIBIT 2011 Exhibit B - Opening 215
`Claim Construction Expert Declaration of
`Dr. Eric Burger
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` DR. THOMAS F. LA PORTA
` P R O C E E D I N G S
` - - - - -
` THE VIDEOGRAPHER: This is the
`start of tape labeled number one of the
`videotaped deposition of Dr. Thomas La Porta in
`the matter of Bright House Networks, LLC, et
`al., versus FOCAL IP, LLC, in the United States
`Patent and Trademark Office before the Patent
`and Trial Appeal Board.
` This deposition is being held at
`1450 South Atherton Street, State College,
`Pennsylvania, on February 23, 2017, at
`approximately 9:45 a.m. My name is Victoria
`Ferrandino from TSG Reporting, and I'm the
`Legal Video Specialist. The court reporter
`today is Michelle Hall in association with TSG
`Reporting.
` The Case numbers are IPR2016-01259,
`IPR2016-01261, IPR2016-01262, and
`IPR2016-01263.
` Will counsel please introduce
`yourself.
` MR. MURPHY: This is John
`Murphy representing the Patent Owner from
`
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` DR. THOMAS F. LA PORTA
`Nelson Bumgardner. With me, I have Bud Bates,
`who is a consultant for the Patent Owner.
` MR. MADBAK: And Hanna Madbak
`with Siber Law.
` MR. TYSON: This is Chris
`Tyson with Duane Morris for the Petitioners.
` MR. McPHERSON: Pat McPherson,
`Duane Morris, Petitioners.
` MS. GUSKE: Sarah Guske from
`Baker Botts for the Petitioners.
` THE VIDEOGRAPHER: Will the
`court reporter please swear in the witness.
` THE COURT REPORTER: Will you
`raise your right hand, please.
` DR. THOMAS F. LA PORTA
`a witness herein, having been first duly sworn,
`was examined and testified as follows:
` - - - - -
` EXAMINATION
`BY MR. MURPHY:
` Q. Good morning, Dr. La Porta.
` A. Good morning.
` Q. It's lovely to be here on your
`campus of Penn State.
`
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` DR. THOMAS F. LA PORTA
` Q. What was the functionality of a
`class 4 switch?
` A. Let me look here. I mean, from a
`connectivity standpoint, class 4 switches were,
`or tandem switches, again, from a connectivity
`standpoint, their primary function was to
`connect either to other class 4 tandem switches
`or to connect to other edge switches.
` Q. Was part of the role of a class 4
`switch to connect to other switches in other
`geographic areas?
` MR. TYSON: Object to the
`form.
` A. Typically, the reason why we would
`go through a class 4 switch was because a call
`was going across geographic areas between two
`different local switches. So I guess yes is
`the short answer.
` Q. So, what would a POSA understand the
`different geographic areas to be?
` A. They would understand a geographic
`area to be an area served by a local switch.
` Q. When you say local switch, do you
`mean a class 5 switch?
`
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` DR. THOMAS F. LA PORTA
`subscribers were attached to different end
`offices used a different procedure. These
`longer distance calls must be routed to tandem
`switches for connection to other edge switches
`in different regions.
` A. I see that, yes.
` Q. So, you use, like, the word "must"
`indicating the only way to go outside the reach
`of the local office is to use a tandem switch?
` MR. TYSON: Object to the
`form.
` Q. Is that right?
` A. I do say that. In reality, there
`are trunk groups between local offices in some
`cases. There I was talking about, you know,
`longer distance calls meaning long-distance
`calls that where you would not have trunks
`between local offices.
` But if the local offices are close
`enough and they have direct trunk groups, then
`you would not have to go through a tandem
`switch.
` Q. But a POSA would understand the
`purpose of a tandem switch would be to go
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` DR. THOMAS F. LA PORTA
`outside the geographical area of the edge
`switch?
` MR. TYSON: Object to the
`form.
` A. Yeah, a POSA would understand a
`tandem switch would connect to other tandem
`switches and other potentially local offices to
`get you from one geographic region to another.
`Yes. So -- so, for routing between two
`geographic regions.
` Q. Okay. So, as part of the hierarchy,
`a POSA would understand that a class 4 switch
`could connect a call to a different geographic
`area, whereas an edge switch could not connect
`the call to a different geographic area?
` MR. TYSON: Object to the
`form.
` A. So, what I would say is a class 4
`switch is used to connect calls to a different
`geographic area. A class 5 switch or -- a
`class 5 switch would not, in the way I'm
`defining geographic area, connect you directly
`to a subscriber in a different geographic area.
` Obviously, it could connect to a
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` DR. THOMAS F. LA PORTA
`that evidences that?
` MR. TYSON: Object to the form
`and scope.
` A. Nothing that I cited to or remember
`right now specifically.
` Q. Based on everything you've cited to
`in your expert report, is it accurate to say
`that the only way a POSA would know how to
`connect to a tandem switch as an edge device
`would be through an edge switch first?
` MR. TYSON: Object to scope.
` A. So, the -- in the examples I've
`given in my technology tutorial and throughout
`the report, yes, they would have to go through
`the -- the edge switch functionality before
`getting to the tandem switch.
` Q. Going back to, like, this hierarchy
`again, we have this concept of tolls. Can you
`explain -- can you explain how a POSA would
`understand tolls in the PSTN and how it
`operates and when do certain tolls get
`incurred?
` A. So, basically, the tolls really
`were, like, long-distance switches. So these
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` DR. THOMAS F. LA PORTA
` A. But for shorthand, if you want to
`say that, I'll just --
` Q. Whenever, like, any time there's a
`voice call to set up the call processing for a
`call, the IAM --
` A. Uh-huh.
` Q. -- is always used to initiate a
`call; correct?
` MR. TYSON: Object to the
`form.
` A. So, an IAM message is what is sent
`between switches to request the connection when
`you are setting up a call, yes. That's always
`the message that -- the ISUP protocol that's
`used.
` Q. Does the -- does the edge switch
`originate the IAM message?
` A. So, an edge switch that is connected
`to a tandem switch using SS7, which most are,
`would send an IAM message to a -- to the tandem
`switch requesting the connection or the call.
` Q. And a tandem switch can receive the
`IAM; is that correct?
` A. Yes, the tandem switch would receive
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` DR. THOMAS F. LA PORTA
`the IAM.
` Q. Can the SCP ever receive the IAM?
` A. So, typically, the SCP functionality
`would not receive an IAM message.
` Q. Why is that?
` A. Because the -- the -- the switching
`part of the phone call is typically implemented
`by the -- the -- the call control function
`inside the switch, and so that's what would
`process the IAM message. What the SCP would
`receive would be information contained in the
`IAM message, but it wouldn't receive the IAM
`message in that format.
` Now, again, the SCP could be
`integrated in with a switch, in which case it's
`all one piece of equipment. So that piece of
`equipment that the SCP is in could receive the
`IAM message. It depends how -- how it's
`implemented.
` Again, the standards talk about
`interfaces. If the interface doesn't exist, if
`you integrate everything, then you don't have
`to implement messages internally. You can just
`receive the message, the IAM message, and
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` DR. THOMAS F. LA PORTA
` Q. Does the SCP receive the ACM
`message?
` MR. TYSON: Object to the
`form.
` A. Again, the SCP, if it's a stand-
`alone SCP, would not receive the ACM message.
`It might -- it might, in some cases, receive
`some of the information in the ACM message or
`an indication that the ACM message was
`received, but it wouldn't receive the ACM
`message itself.
` Q. And what's the next step in the --
` A. It depends. If the user doesn't
`answer, then that's -- that's basically it.
`You know, if the user answered the phone,
`they'll --
` Q. If the user doesn't answer, will
`this be the last message or does it time out
`eventually, or what happened?
` A. Typically --
` MR. TYSON: Object to the
`form.
` A. Typically, switches will not let the
`phone ring forever. So at some point, if a
`
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` DR. THOMAS F. LA PORTA
` Q. Does the SCP ever receive the actual
`ANM message?
` MR. TYSON: Object to the
`form.
` A. Again, a stand-alone SCP during the
`SCP functionality would not receive the answer
`message that I know of, let's put it that way.
` Q. Okay. And then, so, the next step
`when someone terminates the call or ends the
`call?
` MR. TYSON: Object to the
`form.
` Q. I'll rephrase the question since
`terminate is used different ways.
` Was there a different -- does
`anything else happen along the way before
`someone hangs up the call other than the ANM?
` MR. TYSON: Object to the
`form.
` A. So, until someone hangs up the call,
`you typically wouldn't see any signaling
`messages unless the -- unless there was an
`action taken. And by that I mean, for example,
`if someone decided they wanted to add a party
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` DR. THOMAS F. LA PORTA
`of my report, we have a direct trunk group
`between two local offices.
` Q. But this is talking about the
`ability to interconnect one end office to
`another end office.
` A. Yes. So if you look at figure 4. --
` Q. You wouldn't use an edge switch to
`be in the middle of two end offices, would you?
` MR. TYSON: Object to the form
`and scope.
` A. Oh, okay. So if you're saying
`interconnect requires a switch in the middle,
`then you would not use an end office switch to
`be a switch in between two other end offices.
`So, I guess they could connect to end office
`switches and other geographic areas. If they
`were using -- if they were using the word
`interconnect to mean that it provided the
`connection between, then it would not be an end
`office switch that does that, it would be a
`tandem switch. I agree with that.
` Q. Okay. Are you ready to take a
`break?
` A. Sure.
`
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` DR. THOMAS F. LA PORTA
`data in an IAM message, it could conceivably
`receive it. But -- but it rarely receives the
`data that's contained in the IAM message.
` Q. And the secure access platform, that
`does not receive the call or any part of the
`ISUP messages, does it?
` A. So, the secure access platform would
`not receive the ISUP messages, no.
` Q. And the OSN doesn't receive that,
`does it?
` MR. TYSON: Object to the
`form.
` A. So, the OSN would not receive the
`ISUP messages, no.
` Q. And the call would never go through
`the OSN at all?
` MR. TYSON: Object to the
`form.
` A. Well, again, the call could be
`signaling or it could be the voice or both.
`So, I would not expect either of those to go
`through the OSN, no.
` Q. So, in what context does the IP
`signaling -- sorry -- this element 23 in the
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`peripherals. It's -- it's very clear they're
`talking about the intelligent network. So, the
`intelligent network was well known.
` So the fact that they say this
`operates with the intelligent network means it
`can do the services of the intelligent network.
` Q. All right. We'll call it a night
`tonight, follow back up tomorrow morning.
` A. I got to give one more answer here.
` Q. Go for it.
` A. I already cited 7:9 to 16 where I
`explicitly state, the invention enables a
`person surfing the Web to access a
`communication network, preferably the IAM
`telephone network, to control their services.
`So, again, the IAM services allow this, and so
`they're just using the standard IAM services.
` THE VIDEOGRAPHER: The time is
`now 7:24, and we are off the record.
` (Signature not waived.)
` (Whereupon, the above-entitled
`matter was concluded at 7:24 p.m., this date.)
` - - - - -
`
`
`TSG Reporting - Worldwide 877-702-9580
`
`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 18
`La Porta Deposition Excerpts
`IPR2016-01256
`
`
`
`ERRATA SHEET
`
`
`Case Name: Bright House Networks, LLC, et al. v. Focal IP, LLC
`Case Nos.: IPR2016-01259, -01261, -01262 and IPR-01263
`Deposition Date: March 23 and 24, 2017
`Deponent: Dr. Thomas F. La Porta
`
`
`Page Line No.
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`Now Reads
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`“distributor”
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`“one I said it to.”
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`“dial”
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`“you know, phones”
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`Should Read
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`“distributed”
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`“one I cited to.”
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`“dialed”
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`Reason
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`Correction
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`Correction
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`Correction
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`“you know, switches”
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`Correction
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`110
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`12-13
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`14
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`2
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`24
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`26
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`32
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`61
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`70
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`94
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`117
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`138
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`143
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`“servers’ control points”
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`“service control points”
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`Correction
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`12-13
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`“post code”
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`6
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`12
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`“during”
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`“call”
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`“pulse code”
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`“having”
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`“called”
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`Correction
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`Correction
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`Correction
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`143
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`156
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`162
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`165
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`262
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`292
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`299
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`309
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`311
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`13
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`21
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`9
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`20
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`23
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`22-23
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`3-4
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`24
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`15-18
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`“number and the IAM”
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`“number in the IAM”
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`“channels”
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`“corrected”
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`“irrelevant”
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`“channel”
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`“connected”
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`“relevant”
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`“the server processor
`access to”
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`“the server processor has
`access to”
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`“tandem switches 11 to
`PSTN SSM signaling”
`
`
`
`
`
`“tandem switches 11T in
`the PSTN using SS7
`signaling”
`
`Correction
`
`Correction
`
`Correction
`
`Correction
`
`Correction
`
`Correction
`
`“rarely receives the data
`that’s contained in the
`IAM message”
`
`“rarely receives the IAM
`message”
`
`Correction
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`“’013”
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`“IAM”
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`“’113”
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`“AIN”
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`Correction
`
`Correction
`
`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 19
`La Porta Deposition Excerpts
`IPR2016-01256
`
`
`
`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 20
`La Porta Deposition Excerpts
`IPR2016-01256
`
`
`
`Page 313
`
` COMMONWEALTH OF PENNSYLVANIA)
` COUNTY OF ALLEGHENY )
` I, Michelle L. Hall, a Registered
` Merit Reporter and a Notary Public in and for
` the Commonwealth of Pennsylvania, do hereby
` certify that the witness, DR. THOMAS F. LA
` PORTA, was by me first duly sworn to testify
` the truth, the whole truth, and nothing but the
` truth; that the foregoing deposition was taken
` at the time and place stated herein; and that
` the said deposition was recorded
` stenographically by me and then reduced to
` typewriting under my direction, and constitutes
` a true record of the testimony given by said
` witness, all to the best of my skill and
` ability.
` I further certify that the inspection,
` reading and signing of said deposition were not
` waived by counsel for the respective parties
` and by the witness and if after 30 days the
` transcript has not been signed by said witness
` that the witness received notification and has
` failed to respond and the deposition may then
` be used as though signed.
` I further certify that I am not a
` relative, or employee of either counsel, and
` that I am in no way interested, directly or
` indirectly, in this action.
` IN WITNESS WHEREOF, I have hereunto
` set my hand and affixed my seal of office this
` 27th day of February, 2017.
`
` S/Michelle L. Hall, RMR
` ----------------------------
` ----------------------------
`
`TSG Reporting - Worldwide 877-702-9580
`
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`YMAX CORPORATION v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 21
`La Porta Deposition Excerpts
`IPR2016-01256
`
`